Lion's office will be closed on Monday, September 1, in observance of Labor Day. For help with online training, please contact support@lion.com.
Search

Simplify Your Approach to Waste ID

Posted on 1/28/2014 by James Griffin

Identifying hazardous waste and assigning waste codes is one of the most complex responsibilities in waste management. Many factors need to be considered when making this determination, including the waste’s properties, the hazards it poses, and even the industry in which it was generated.
 
The EPA’s Resource Conservation and Recovery Act (RCRA) regulations provide a complex system of lists that personnel must use to identify their hazardous waste. Understanding what kinds of waste are on each of these lists, and knowing which lists’s codes apply in a given situation, makes the waste ID process much less daunting than it seems at first glance.
 
The EPA’s definition of a hazardous waste has two parts that are important for performing waste ID. The EPA defines hazardous waste as a solid waste that exhibits a hazardous characteristic and/or is specifically listed by the EPA as hazardous. [40 CFR 261.3]
 
Characteristic Wastes
 
First, wastes that “exhibit a hazardous characteristic” are hazardous waste. There are four “hazardous characteristics” to consider: ignitibility, corrosivity, reactivity (including explosive unstable materials and water-reactive materials), and toxicity (a list of 40 chemical substances). [40 CFR 261, Subpart C]
 
 
Listed Wastes
 
Other wastes are “specifically listed by the EPA as hazardous.” There are four lists of hazardous waste in the RCRA regulations: wastes from non-specific sources (the F list), wastes from specific sources (the K list), acutely hazardous chemical products (the P list), and toxic/other chemical products (the U list). [40 CFR 261, Subpart D]
 Understanding these lists and how, when, and where they apply is critical for performing waste ID. Here is a summary of what hazardous wastes might be found on each list.
 
 
Hazardous Waste from Non-specific Sources
 
The F list at 40 CFR 261.31 includes hazardous wastes from non-specific sources. That means the wastes listed here are not specifically associated with particular industrial sectors. The list includes 28 waste streams in the following categories: five kinds of spent solvents, eight secondary materials from metal finishing, nine types of waste from the manufacture of dioxins and chlorinated organics, two types of oil/water separation sludge, and multi-source leachate (e.g., garbage juice from a landfill).
 
F-listed hazardous wastes are generally toxic, but they may also be ignitable or exhibit other characteristics.
 
 
Hazardous Waste from Specific Sources
 
The K list at 40 CFR 261.32 includes hazardous wastes from specific sources. That means the wastes listed here are associated with particular industrial sectors. The list includes over 150 wastewater treatment sludges, still bottoms, by-products, and other secondary materials generated from the production of pigments, inks, pesticides, explosives, pharmaceuticals, and other organic and inorganic chemicals; secondary materials from petroleum refining sludge and other by-products of smelting iron, steel, aluminum, lead, and coke; and certain residues used in wood preserving. K-listed hazardous wastes are generally toxic, though they may exhibit reactivity or other characteristics.
 
 
Acute and Toxic Hazardous Wastes
 
The P list at 40 CFR 261.33(e) is for commercial chemical products that are acutely hazardous. Acutely hazardous wastes are those that have acute toxic effects on organisms, meaning they have the potential to cause immediate death upon exposure.
 
The U list at 40 CFR 261.33(f) is primarily for commercial chemical products with toxic hazards. “Toxic” in this context means wastes that have the potential to cause cancer or other chronic health defects upon exposure. The list also includes a few named chemicals with ignitable, corrosive, or reactive properties.
 
Understanding the EPA’s various hazardous waste lists is the first step to a practical, streamlined approach to performing waste ID. At the Hazardous/Toxic Waste Management Workshop, you can satisfy the EPA’s annual training requirement for hazardous waste personnel and learn best practices for managing waste from “cradle to grave.” Presented nationwide by expert Lion instructors, this engaging two-day workshop is designed for EHS and hazardous waste personnel of any experience level.

Tags: hazardous, RCRA, waste

Find a Post

Compliance Archives

Lion - Quotes

I have been to other training companies, but Lion’s material is much better and easier to understand.

Mark Abell

Regional Manager

The course is well thought out and organized in a way that leads to a clearer understanding of the total training.

David Baily

Hazmat Shipping Professional

Lion's training was by far the best online RCRA training I've ever taken. It was challenging and the layout was great!

Paul Harbison

Hazardous Waste Professional

These are the best commercial course references I have seen (10+ years). Great job!

Ed Grzybowski

EHS & Facility Engineer

Convenient; I can train when I want, where I want.

Barry Cook

Hazmat Shipping Professional

This was the 1st instructor that has made the topic actually enjoyable and easy to follow and understand. Far better than the "other" training providers our company has attended!

Lori Hardy

Process & Resource Administrator

The instructor had knowledge of regulations and understanding of real-world situations. The presentation style was engaging and fostered a positive atmosphere for information sharing.

Linda Arlen

Safety & Environmental Compliance Officer

The instructor was energetic and made learning fun compared to dry instructors from other training providers.

Andy D’Amato

International Trade Compliance Manager

Lion is my preferred trainer for hazmat and DOT.

Jim Jani

Environmental Coordinator

One of the best trainings I have ever received!

Brandon Morfin

EH&S Manager

Download Our Latest Whitepaper

Decrease spill, release, and injury risk and increase savings with these "source reduction" strategies to prevent unused chemicals from becoming regulated as hazardous waste.

Latest Whitepaper

By submitting your phone number, you agree to receive recurring marketing and training text messages. Consent to receive text messages is not required for any purchases. Text STOP at any time to cancel. Message and data rates may apply. View our Terms & Conditions and Privacy Policy.